`
`From:
`Sent:
`To:
`Cc:
`
`Subject:
`
`Eric Green <egreen@McKoolSmith.com>
`Monday, July 11, 2016 7:02 PM
`Justin Nemunaitis
`rapid@caldwellcc.com; Baker Hughes; Leslie V. Payne (lpayne@hpcllp.com); Chris First
`<cfirst@hpcllp.com> (cfirst@hpcllp.com); dwilson@hpcllp.com; peak.counsel@raleybowick.com; 'Tim
`Johnson' (tim.johnson@peakcompletions.com)
`BH/RC: Invalidity Contention Supplementation
`
`Follow Up Flag:
`Flag Status:
`
`Follow up
`Flagged
`
`Justin,
`
`
`As a courtesy, I write to inform you that the Defendants are planning to update our invalidity contentions to include
`certain prior art references that were recently disclosed by Packers Plus in connection with the 501 patent. Additionally,
`we plan to amend to include prior art that was only recently located. We also plan to supplement with prior art that
`relates to positions taken by Rapid Completions in its recent IPR filings. The additional art includes, but is not necessarily
`limited to:
`
`
`‐ US 2,537,066 (Grant)
`‐ US 3,289,762 (Schell)
`‐ US 1,510,669 (Halliday)
`‐ US 2387003 (Barnes)
`‐ US 2307983 (Barnes)
`‐ SPE 19090
`‐ SPE 17759
`‐ SPE 18249
`‐ SPE 17760
`‐ SPE 16681
`‐ SPE 16410
`‐ The Composite Catalog of Oil Field and Pipe Line Equipment, 21st 1956‐57 Edition, Volume 2, published by
`World Oil
`‐ The Lane Wells Tubing Port Valve, as described in various Lane Wells publications that have recently been
`produced
`‐ Lane Wells Packers described in various Lane Wells publications that have recently been produced
`‐ The Composite Catalog of Oil Field Equipment and Services, 26th 1964‐65 Edition, Volume 2, published by World
`Oil
`‐ Lynes inflatable packers, including the Lynes Inflata‐Plug, Lynes Production‐Injection Packer, Lynes Open Hole
`Packer, and Lynes Straddle Packer
`
`
`
`Our search efforts are ongoing, and we reserve the right to add additional art as it becomes available and after our
`review of Rapid Completions’ supplements to its infringement contentions as ordered by the Court.
`
`
`Regards,
`
`
`Eric
`
`
`
`1
`
`1 of 2
`
`Exhibit 2034
`IPR2016-01517
`
`
`
`
`Eric C. Green | Associate
`McKool Smith | 300 W. 6th Street | Suite 1700
`Austin, Texas 78701 | Phone: 512.692.8732
`Fax: 512.692.8744 | Mobile 512.565.8932
`Email: egreen@mckoolsmith.com
`Website: www.mckoolsmith.com
`
`
`NOTICE OF CONFIDENTIALITY:
`
`
`The information contained in and transmitted with this e-mail is SUBJECT TO THE ATTORNEY-CLIENT and ATTORNEY WORK PRODUCT PRIVILEGE and is
`CONFIDENTIAL. It is intended only for the individual or entity designated above. You are hereby notified that any dissemination, distribution, copying, use or
`reliance upon the information contained in and transmitted with this e-mail by or to anyone other than the addressee designated above by the sender is
`unauthorized and strictly prohibited. If you have received this e-mail in error, please notify the sender by reply immediately. Any e-mail erroneously transmitted to
`you should be immediately destroyed.
`
`
`2
`
`2 of 2
`
`Exhibit 2034
`IPR2016-01517
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